physically separate frames are "dynamically isolated" when applying the broadest reasonable
interpretation of that claim term.
Van Engelen's definition of "dynamically isolated" is derived by viewing the term in light
of van Engelen's specification, resulting in an importation of a structural element that is not part
of the count. Van Engelen's definition for dynamically isolated is not the broadest reasonable
interpretation of that term. When the term "dynamically isolated" is properly construed, the Lee
'558 application provides an enabling embodiment within the scope of the count.
Van Engelen's proposed definition of dynamic is the second listed definition, and the
example for that definition is that of a dynamic market (Ex. 2016). Van Engelen provides no
explanation why the term "dynamic" or dynamically should be interpreted under the second
listed definition as opposed to the first definition. Note, that Dr. Kurfess, van Engelen's expert,
provides no explanation as to why the proposed second definition is what one of ordinary skill in
the art would understand the definition to be (Ex. 2012 ý 49). Generally, it is the first listed
definition that is the most commonly used definition for a given word. A dynamic market would
appear to have nothing to do with two mechanical frames and the relationship between those two
frames. Furthermore, van Engelen's proposed definition would require a structural element
between the two frames. Lee's claim 4, however, does not recite an element for isolating the two
frames. Rather, the claim merely recites the relationship between the two frames. The
relationship is described by the term dynamically isolated. We will not read limitations into
Lee's claims that would require an element to be in between the two frames. Lee's claim 4 is not
so limiting. Van Engelen's proposed definition is ultimately obtained by looking to its own
specification and importing limitations from its specification into the count. However, the count
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